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IRC 751 Hot Assets and the Sale of Partnership Interests

Gain insight into the issues presented when you are involved in the construction, structuring, and/or reporting of ownership transactions.

IRC Sec. 751 contains some of the more difficult rules to navigate in Subchapter K, and have potential implications with every partnership/LLC ownership transaction. The aggressive bonus depreciation rules of recent years increase the potential for Sec. 751 implications. Likewise, the proliferation of disproportionate allocation structures and the use of different classes of ownership interests increases the complexities inherent in trying to apply Sec. 751 to actual transactions. This topic will give you the information you need to be conversant in the issues presented when you are involved in the construction, structuring, and/or reporting of ownership transactions.

Learning Objectives

  • You will be able to identify basic principles of Section 751.
  • You will be able to differentiate between the Aggregate Theory and the Entity Theory.
  • You will be able to identify categories of Hot Assets.
  • You will be able to identify the requirements of Form 8308.

Runtime: 62 minutes
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Why Lorman?

Over 33 years and 1.4 million customers worth of experience providing continuing education. Our passion is providing you world-class training to help you succeed in business and as a professional.

Agenda

What Is Sec. 751 and When Does It Come Into Play?

  • Overview and History of Sec. 751 Under the Aggregate Theory of Taxation
  • Sec. 751(a) - Transfer of Partnership Interest
  • Sec. 751(b) - Distribution of Partnership Property
  • Hot Assets
    • Unrealized Receivables
    • Inventory
    • Substantially Appreciate Inventory

Review of the Sec. 751 Regulations and Other Authorities

  • Overview of Existing Regulations
  • Overview of 2014 Proposed Regulations
  • Discussion of Primary Areas for Which Guidance Remains Lacking

Illustrate the Application of Sec. 751 in the Context of Typical Transactions

  • Potential Structure Considerations and Alternatives
  • Buyer and Seller Negotiating Points
  • Form 8308 and Other Reporting Requirements
  • Potential Sec. 751 Impact on a Sec. 736 Transaction
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Why Lorman?

Over 33 years and 1.4 million customers worth of experience providing continuing education. Our passion is providing you world-class training to help you succeed in business and as a professional.

Credits

OnDemand Webinar

This course was last revised on March 6, 2020.

Call 1-866-352-9540 for further credit information.

  • CPE/NASBA - QAS Self Study 1.2 including Taxes 1.2
     
  • Lorman Education Services is registered with the National Association of State Boards of Accountancy (NASBA) as a QAS Self Study sponsor of continuing professional education on the National Registry of CPE Sponsors. State boards of accountancy have final authority on the acceptance of individual courses for CPE credit. Complaints regarding registered sponsors may be submitted to the National Registry of CPE Sponsors through its web site: https://www.nasbaregistry.org/cpas/complaints. For more information regarding administrative policies such as complaint and refund, please contact our offices at 866-352-9539. CPE Credit: Maximum Credit Hours: 1.2 each session (based on a 50 minute credit hour). You must attend at least 50 minutes to obtain credit. Field of Study: Taxes for 1.2 hours. Prerequisite: . Level of Knowledge: Intermediate. Teaching Method: Seminar/Lecture. Advance Preparation: None. Delivery Method: QAS Self Study. Please refer to the information in this advertisement for outline, course content and objectives. Upon completion of this course, you will receive a certificate of attendance. Final approval of a course for CPE credit belongs with each state's regulatory board.
     
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Why Lorman?

Over 33 years and 1.4 million customers worth of experience providing continuing education. Our passion is providing you world-class training to help you succeed in business and as a professional.

Faculty

Joseph Schlueter

Joseph Schlueter

Baker Tilly Virchow Krause, LLP

  • Tax director in the Minneapolis office of Baker Tilly Virchow Krause, LLP
  • Over 30 years of experience in public accounting, and over 20 years as a national tax resource in national accounting firms on all matters related to the taxation of partnerships
  • Extensive experience advising small, middle market and closely held business clients on structuring acquisition, disposition, and ownership succession transactions and the related tax implications
  • Active for more than 20 years in preparing and presenting webcasts and seminars for CPE and CLE organizations
  • J.D. degree, University of Iowa, College of Law; B.A. degree in accounting, University of Northern Iowa
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Why Lorman?

Over 33 years and 1.4 million customers worth of experience providing continuing education. Our passion is providing you world-class training to help you succeed in business and as a professional.

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Product ID: 407643
Published 2020
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